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15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation. ...

(February 1990 Access Letter, ¶1124)-- summary under Section 255 Summary Under Tax Topics- Income Tax Act- Section 255 Neither section 255 of the Act, nor section 5 of the Income Tax Conventions Interpretation Act, are relevant to the interpretation of the "in Canada" requirement in s. 127(9). ...

No. 2, p. 4, ¶1047)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 In the case of a corporation incorporated in Canada and having its place of effective management in The Netherlands, Canada will not agree that the corporation is a resident of The Netherlands in the absence of evidence that Canadian tax is not being avoided. ...

T.I. 921585 (December 1992 Access Letter, p. 24, ¶C111-048)-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 A Canadian citizen who is employed at the Canadian embassy in Washington will be subject to tax in Canada even after he has acquired U.S. citizenship. ...

20 February 2003 External T.I. 2002-014360-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 A s. 20(12) deduction may not be taken by a U.S. citizen resident in Canada on the withholding from U.S. source property income that is in excess of a rate of 10% and less than a 15% rate. ...

21 December 2009 External T.I. 2009-0330491E5- Article XXI Exemption-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 IV(7)(b) of Canada-U.S. ...

8 September 2017 External T.I. 2014-0549771E5- Article XXIX-A:3-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 "person related thereto" defined by ITA meaning of "related person" After noting the relevance of domestic definitions of a term under Art. ...

18 April 2001 External T.I. 2001-0074995 F- Indemnité journalière de grossesse de France-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) French maternity allowances were taxable CCRA indicated that daily pregnancy benefits paid by the French government constituted income which was taxable for Canadian tax purposes, and was not exempted under the Canada-France Convention. ...

9 January 2001 External T.I. 2000-0042545- Immovable property-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The exception for real property in which the business of the enterprises carried on apparently was viewed as being available where the shares of a private corporation resident in Canada actively carried on a farming business in Canada. ...

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